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Home My Public Portal AboutPublic Comment #062 (Eisele)To: Denyelle Nishimori, Senior Planner November 14, 2014 10183 Truckee Airport Road Truckee, CA 96161 dnishimori @townoftruckee.com Re: Comments for Canyon Springs RDEIR Dear Ms. Nishimori: Please find below comments and concerns regarding the RDEIR for the proposed Canyon Springs development. Although we have many concerns about all sections of the RDEIR, we will confine these comments to the section on Transportation and Traffic (beginning on page 4.14 -1). 1. Timing of the traffic analyses appears to be less than optimal for gaining accurate data on traffic. The Canyon Springs Traffic Analysis Addendum prepared by LSC Transportation. and Consultants, Inc. is dated January 17, 2014 (pg. 4.14 -1). The traffic analysis was supposed to analyze the School Season AM & PM peak travel times. If the analysis was conducted December 26, 2013 - January 17, 2014, as I understand it was, this would have occurred while school was out for winter break. If this is true, these RDEIR traffic counts would be invalid for the purpose of collecting data during school in session. This needs to be re- evaluated to be sure that the timing of the study was appropriate and that the numbers generated.meet peer.review. Also, Table 4.14 -6 shows. that the project will generate up to 2,578 one -way vehicle trips a day. Numbers of 194 trips during the AM peak and 257 during the PM peak do not seem to correlate with a total of up to 2,578 trips. These peak time numbers seem unrealistically low. When does the model predict the rest of the daily trips will occur, if not at the peak hours? The data needs to be re- evaluated and peer reviewed. 2. The RDEIR states that the 2011 Truckee TransCad traffic model assumes build -out of the General Plan by 2025; the RDEIR assumes no further growth in traffic from 2025 to 2031 (pg. 4.14 -19). How can this assumption be made with the proposed Canyon Springs project, which would increase development during a build -out period of 20+ years? This is in conflict. Glenshire also has a number of already- approved developments that have not been built, not to mention development that could be proposed for adjacent areas in the Town of Truckee sphere of influence. The "no growth in traffic" assumption from 2025 -2031 appears to be invalid. Please explain and analyze. 3. Driver sight distances are not adequate at the Whitehorse / Glenshire Drive intersection. The RDEIR states that "Whitehorse Rd. looking to the west along Glenshire Dr. is roughly 195.feet, which does not.meet the Town's 330 -ft requirement" (Pg. 4.14- 27), and "impacts to drivers on Whitehorse Road would be potentially significant" (Pg. 4.14 -53). Because of the way, the intersection occurs at the top of the hill, the curves on Glenshire Drive, and visual obstacles, this intersection has .poor visibility. To say that impacts are less than significant and no mitigation is warranted (p. 4.14 -55) based on historical accident numbers does not appear to take into account the estimated 2,000 more vehicles in and out of Martis Peak Road or the increased traffic on the section of Glenshire Drive to the east of this intersection with the Canyon Springs project. Mitigation is inadequate. 4. In the section on Roadway Segment Hazards (Pg. 4.14 -56), the Glenshire Drive east of Martis Peak Road segment is stated to be "deficient with respect to the current County standards" related to the 9% grade and narrowness of the travel lanes and shoulders, not to mention the curves, and hazards due to the resident deer population. The RDEIR makes the assumption that the majority of project related traffic, except for trips to downtown Truckee and Glenshire, will use Hirschdale Road (Pg. 4.14 -30). Additionally, the RDEIR states "the accident rate along this roadway segment is higher than State and County averages" (Pg. 4.14 -57). When describing the accident records with regard to injuries and properly damage, it is not indicated how many of these accidents involve the Loyalton - Truckee deer herd animals that frequent this section of road. How can the RDEIR conclude that the Canyon Springs project, which will "result in an increase of up to 1,600 daily one -way trips including 160 peak hour trips on this roadway segment' ' will have impacts that are less than significant, based on minor improvements made in 2008- 9? Please explain how one can make this conclusion. 5. There will be more bicyclists and boat - towing vehicles (from Canyon Springs) going up and down Glenshire Dr between Martis Peak Rd. and Interstate 80, en route to and from Stampede and Boca recreational areas. This is a significant impact, which needs to be analyzed, both for bicycle safety and road congestion impacts. 6. While they say it is "speculative to try and predict potential traffic impacts" based on weather and road conditions and driver behavior and then go on to say that "incident of vehicular and wildlife collisions is an expected and unpredictable hazard" (Pg. 4.14 -57), it is not rocket science to figure that increasing the traffic on this steep hill by 1,600 trips a day will add to already existent hazards. The mini lecture on this same page about driver responsibility is not mitigation. The insensitive statement about collisions with wildlife being expected does nothing to mitigate the impact of increased traffic on this road segment on the Loyalton- Truckee deer herd (addressed in others' comments on the Biological Resources section of the RDEIR), nor on the drivers who may have the misfortune of running into them. Additionally, the traffic analysis for the whole project does not figure in how driver behavior may change with increased interactions with the deer. More people may end up using Glenshire Drive west than anticipated, requiring reassessment of impacts on the west end of Glenshire Drive. Impacts of this increased traffic on the deer herd population and its migration corridor need to be analyzed. 7. A major concern is the impact of increased traffic on the already Level of Service (LOS) F intersection at Donner Pass Road and Glenshire Drive. The RDEIR states that LOS impacts of the Canyon Springs project on this intersection would be significant (Pg. 4.14 -45). Even with the proposed Donner Pass Road left turn lane improvement, this project will result in regression back to pre - improvement levels (back to a LOS F and excessive vehicle delays at peak summer PM conditions). Another way of saying this is that, with this project, this intersection would go back to unacceptable with a LOS of F and exceeding the 4 -hour delay allowed by 1.6 hours (Pg. 4.14 -43, Table 4.14 -10). How will mitigation occur with this threshold being exceeded? What is the point of improving the intersection if we end up with the same LOS traffic problems (F) we had before, due to the Canyon Springs development? This intersection problem is already intolerable to and viewed unsafe by many Glenshire residents. This is counter to the Town of Truckee General Plan Circulation Goal CIRC -2, Policy P2.1. (Table 4.14 -1) It is also not evident if the impacts from the addition of the center turn lane and increased traffic at Glenshire Road/ Donner Pass Road on traffic turning left from Keiser Avenue onto Donner Pass Road have been studied. Since many people use this route, this needs to be included in the traffic analysis. 8. Finally, here are some apparent examples of conflicts between the project and Town of Truckee General Plan (TOTGP) traffic circulation goals and policies (Table 4.14 -1): a) Goal CIRC -4: "Create new developments that are integrated into the circulation network and promote connectivity within and between community areas" and "located in close proximity to commercial services" (CIRC P. 4 -2, Pg. 4.14 -59). The Canyon Springs project area is peripheral on the outskirts of town and in no way can be viewed to be integrated and connected within areas of town. Rather it represents sprawl. The project is not consistent with the goal and policies. b) Goal CIRC -6, P.6.1: Prevent adverse impacts to water quality and significant biological resources. The impact of increased traffic on the Loyalton- Truckee deer herd addressed above seems to conflict with this goal. c) . CIRC -11, P. 11.1: Encourage transit use. This goal cannot be met by this project because the proposed development is far from the town center and is not served by public transit. Instead, it represents sprawl and will obligate more people to use cars to get to commercial centers, medical services, etc. How can the RDEIR conclude that "the project would not conflict with these and other adopted policies ... ", etc. and that this is less than significant? This conclusion is conflicting and needs to be re- evaluated for validity. There are other concerns regarding the effects of increased traffic from Canyon Springs, including the safety of neighborhood children using the streets. The concerns are too numerous to address in this letter. Thank you for your consideration. Sincerely,% ,=G John Eisele M.D. �"""� Pamela Eisele ,%' , 10925 Whiteh "e Road, Truckee 96161 jeisele4 @gmail.com 1 3